ML050950588
| ML050950588 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 05/26/2005 |
| From: | Dick G NRC/NRR/DLPM/LPD3 |
| To: | Crane C Exelon Corp |
| Dick G F, NRR/DLPM, 415-3019 | |
| Shared Package | |
| ML051400142 | List: |
| References | |
| TAC MC4489, TAC MC4490, TAC MC4491, TAC MC4492 | |
| Download: ML050950588 (20) | |
Text
May 26, 2005 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BYRON STATION, UNITS 1 AND 2 AND BRAIDWOOD STATION, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: HYDROGEN RECOMBINERS AND HYDROGEN MONITORS (TAC NOS. MC4491, MC4492 AND MC4489, AND MC4490)
Dear Mr. Crane:
The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed, Amendment No. 143 to Facility Operating License No. NPF-37 and Amendment No. 143 to Facility Operating License No. NPF-66 for the Byron Station Units 1 and 2, respectively, and Amendment No. 137 to Facility Operating License No. NPF-72 and Amendment No. 137 to Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, respectively.
The amendments are in response to Exelon Generation Company, LLC application dated September 15, 2004.
The amendments delete the Technical Specification (TS) requirements to maintain hydrogen recombiners, hydrogen monitors, and related Surveillance Requirements. The revised Title 10 of the Code of Federal Regulations (10 CFR) Section 50.44, "Combustible Gas Control for Nuclear Power Reactors," eliminated the requirements for hydrogen recombiners and relaxed safety classifications and licensee commitments to certain design and qualification criteria for hydrogen and oxygen monitors.
A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
George F. Dick, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456, and STN 50-457
Enclosures:
- 1. Amendment No. 143 to NPF-37
- 2. Amendment No. 143 to NPF-66
- 3. Amendment No. 137 to NPF-72
- 4. Amendment No. 137 to NPF-77
- 5. Safety Evaluation cc w/encls: See next page
Byron/Braidwood Stations cc:
Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355 Pittsburgh, PA 15230-0355 Joseph Gallo Gallo & Ross 1025 Connecticut Ave., NW, Suite 1014 Washington, DC 20036 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Dr., Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, IL 61010-9750 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 George L. Edgar Morgan, Lewis and Bockius 1800 M Street, NW Washington, DC 20036-5869 Attorney General 500 S. Second Street Springfield, IL 62701 Illinois Emergency Management Agency Division of Disaster Assistance &
Preparedness 110 East Adams Street Springfield, IL 62701-1109 Byron Station Plant Manager Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Site Vice President - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 County Executive Will County Office Building 302 N. Chicago Street Joliet, IL 60432 Braidwood Station Plant Manager Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, IL 60935
Byron/Braidwood Stations Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President of Operations - Mid-West Pressurized Water Reactors Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Regulatory Assurance Manager - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood, Byron and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Barry Quigley 3512 Louisiana Rockford, IL 61108
ML050950588 Pkg No.: ML051400142 OFFICE PM:LPD3-2 LA:LPD3-2 LPM:TSTF-447 SC:LPD3-2 NAME GDick PCoates WReckley GSuh DATE 05/26/05 05/24/05 5/13/05 05/26/05
EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-454 BYRON STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 143 License No. NPF-37 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (the licensee) dated September 15, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-37 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 143 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license.
The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by JHopkins for/
Gene Y. Suh, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 26, 2005
EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-455 BYRON STATION, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 143 License No. NPF-66 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (the licensee) dated September 15, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-66 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A (NUREG-1113), as revised through Amendment No. 143 and the Environmental Protection Plan contained in Appendix B, both of which were attached to License No. NPF-37, dated February 14, 1985, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by JHopkins for/
Gene Y. Suh, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 26, 2005
ATTACHMENT TO LICENSE AMENDMENT NOS. 143 AND 143 FACILITY OPERATING LICENSE NOS. NPF-37 AND NPF-66 DOCKET NOS. STN 50-454 AND STN 50-455 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.
Remove Pages Insert Pages 3.3.3-2 3.3.3-2 3.3.3-3 3.3.3-3 3.3.3-4 3.3.3-4 3.6.8-1 3.6.8-1 3.6.8-2 5.6-5 5.6-5
EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-456 BRAIDWOOD STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 137 License No. NPF-72 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (the licensee) dated September 15, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-72 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 137 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by JHopkins for/
Gene Y. Suh, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 26, 2005
EXELON GENERATION COMPANY, LLC DOCKET NO. STN 50-457 BRAIDWOOD STATION, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 137 License No. NPF-77 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (the licensee) dated September 15, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-77 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 137 and the Environmental Protection Plan contained in Appendix B, both of which were attached to License No. NPF-72, dated July 2, 1987, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date if its issuance and shall be implemented within 120 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by JHopkins for/
Gene Y. Suh, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 26, 2005
ATTACHMENT TO LICENSE AMENDMENT NOS. 137 AND 137 FACILITY OPERATING LICENSE NOS. NPF-72 AND NPF-77 DOCKET NOS. STN 50-456 AND STN 50-457 Replace the following pages of the Appendix "A" Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.
Remove Pages Insert Pages 3.3.3-2 3.3.3-2 3.3.3-3 3.3.3-3 3.3.3-4 3.3.3-4 3.6.8-1 3.6.8-1 3.6.8-2 5.6-5 5.6-5
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 143 TO FACILITY OPERATING LICENSE NO. NPF-37, AMENDMENT NO. 143 TO FACILITY OPERATING LICENSE NO. NPF-66, AMENDMENT NO. 137 TO FACILITY OPERATING LICENSE NO. NPF-72, AND AMENDMENT NO. 137 TO FACILITY OPERATING LICENSE NO. NPF-77 EXELON GENERATION COMPANY, LLC BYRON STATION, UNITS 1 AND 2 BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-454, STN 50-455, STN 50-456 AND STN 50-457
1.0 INTRODUCTION
By application dated September 15, 2004, Exelon Generation Company, LLC (the licensee) requested changes to the Technical Specifications (TSs) for the Braidwood and Byron Stations.
The staffs original proposed no significant hazards consideration determination was published in the Federal Register on February 1, 2005 (70 FR 5243).
The Nuclear Regulatory Commission (NRC) has revised Section 50.44 of Title 10 of the Code of Federal Regulations (10 CFR), "Standards for Combustible Gas Control System in Light-water-Cooled Power Reactors." The amended standards eliminate the requirements for hydrogen recombiners and relaxed the requirements for hydrogen and oxygen monitoring. In letters dated December 17, 2002, and May 12, 2003, the Nuclear Energy Institute (NEI)
Technical Specification Task Force (TSTF) proposed to remove requirements for hydrogen recombiners and hydrogen and oxygen monitors from the standard technical specifications (STS) (NUREG 1430 - 1434) on behalf of the industry to incorporate the amended standards.
This proposed change is designated TSTF-447.
The NRC staff prepared this model safety evaluation (SE) for the elimination of requirements regarding containment hydrogen recombiners and the removal of requirements from the TSs for containment hydrogen and oxygen monitors and solicited public comment (67 FR 50374, published August 2, 2002) in accordance with the Consolidated Line Item Improvement Process (CLIIP). The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the hydrogen recombiners and hydrogen and oxygen monitors requirements from the TSs. Licensees of nuclear power reactors to which this model applies were informed (68 FR 55416; September 25, 2003) that they could request amendments conforming to the model, and, in such requests, should confirm the applicability of the SE to their reactors and provide the requested plant-specific verifications and commitments.
The proposed changes would delete the TS requirements related to hydrogen recombiners and the hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 26, 2003. The deletion of the requirements for the hydrogen recombiner and requirements for hydrogen monitors resulted in numbering and formatting changes to other TSs, which were otherwise unaffected by this proposed amendment. Specifically the proposed changes would revise the following for both Braidwood and Byron Stations:
1.1 TS Section 3.3.3F would be deleted, as well as TS Table 3.3.3-1, Item number 15, "Post Accident Monitoring Instrumentation," Hydrogen Monitors, and all of TS Section 3.6.8, "Hydrogen Recombiners."
1.2 Surveillance Requirement (SR) SR 3.6.8.1, "Perform a system functional test for each hydrogen recombiner every 18 months," SR 3.6.8.2, "Visually examine each hydrogen recombiner enclosure and verify there is no evidence of abnormal conditions every 18 months," and SR 3.6.8.3, "Perform a resistance to ground test for each heater phase every 18 months," would be deleted.
2.0 REGULATORY EVALUATION
Regulatory Issue Summary 2000-06, Consolidated Line Item Improvement Process for Adopting Standard Technical Specification Changes for Power Reactors, was issued on March 20, 2000. The CLIIP is intended to improve the efficiency of NRC licensing processes.
This is accomplished by processing proposed changes to the STS in a manner that supports subsequent license amendment applications. The CLIIP includes an opportunity for the public to comment on proposed changes to the STS following a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. The NRC staff evaluates any comments received for a proposed change to the STS and either reconsiders the change or proceeds with announcing the availability of the change for proposed adoption by licensees. Those licensees opting to apply for the subject change to the TSs are responsible for reviewing the staff's evaluation, referencing the applicable technical justifications, and providing any necessary plant-specific information. Each amendment application made in response to the notice of availability would be processed and noticed in accordance with applicable rules and NRC procedures.
The Commissions regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36. This regulation requires that the TSs include items in five specific categories.
These categories include: 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation (LCO), 3) surveillance requirements, 4) design features, and 5) administrative controls. However, the regulation does not specify the particular TS to be included in a plants license.
Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TSs. These criteria are as follows:
1.
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
2.
A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier.
3.
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
4.
A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Existing LCOs and related surveillances included as TS requirements which satisfy any of the criteria stated above must be retained in the TSs. Those TS requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents.
As part of the rulemaking that revised 10 CFR 50.44, the Commission retained requirements for ensuring a mixed atmosphere, inerting Mark I and II containments, and providing hydrogen control systems capable of accommodating an amount of hydrogen generated from a metal-water reaction involving 75 percent of the fuel cladding surrounding the active fuel region in Mark III and ice condenser containments. The Commission eliminated the design-basis loss-of-coolant accident (LOCA) hydrogen release from 10 CFR 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 10 CFR 50.44 while relaxing safety classifications and licensee commitments to certain design and qualification criteria. The Commission also relocated without change the hydrogen control requirements in 10 CFR 50.34(f) to 10 CFR 50.44 and the high point vent requirements from 10 CFR 50.44 to 10 CFR 50.46a.
3.0 EVALUATION The ways in which the requirements and recommendations for combustible gas control were incorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the Three Mile Island (TMI), Unit 2 accident are likely to have been the subject of confirmatory orders that imposed the combustible gas control functions described in NUREG-0737, Clarification of TMI Action Plan Requirements, as obligations. The issuance of plant specific amendments to adopt these changes, which would remove hydrogen recombiner and hydrogen and oxygen monitoring controls from the TSs, supersede the combustible gas control specific requirements imposed by post-TMI confirmatory orders.
3.1 Hydrogen Recombiners The revised 10 CFR 50.44 no longer defines a design-basis LOCA hydrogen release, and eliminates requirements for hydrogen control systems to mitigate such a release. The installation of hydrogen recombiners and/or vent and purge systems required by 10 CFR 50.44(b)(3) was intended to address the limited quantity and rate of hydrogen generation that was postulated from a design-basis LOCA. The Commission has found that this hydrogen release is not risk-significant because the design-basis LOCA hydrogen release does not contribute to the conditional probability of a large release up to approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the onset of core damage. In addition, these systems were ineffective at mitigating hydrogen releases from risk-significant beyond design-basis accidents. Therefore, the Commission eliminated the hydrogen release associated with a design-basis LOCA from 10 CFR 50.44 and the associated requirements that necessitated the need for the hydrogen recombiners and the backup hydrogen vent and purge systems. As a result, the staff finds that requirements related to hydrogen recombiners no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in the TSs and the existing TS requirements may, therefore, be eliminated.
3.2 Hydrogen Monitoring Equipment Section 50.44(b)(1), the STS, and plant-specific TSs currently contain requirements for monitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in Item II.F.1, Attachment 6 of NUREG-0737 and Regulatory Guide (RG) 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident. The hydrogen monitors are required to assess the degree of core damage during a beyond design-basis accident and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered.
The hydrogen monitors are needed to implement these severe accident management strategies.
With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are no longer required to mitigate design-basis accidents and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends classifying the hydrogen monitors as Category 1. RG 1.97 Category 1, is intended for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events and, therefore, are items usually addressed within the TSs. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that the hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. The Commission concluded that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required to diagnose the course of beyond design-basis accidents. Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Section 4 of Attachment 2 to SECY-00-0198, Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option
- 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control), found that the hydrogen monitors were not risk-significant. Therefore, the staff finds that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in the TSs and, therefore, may be relocated to other licensee-controlled documents. However, because the monitors are required to diagnose the course of beyond design-basis accidents, each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.
The elimination of Post-Accident Sampling System requirements from some plant-specific TSs (and associated CLIIP notices) indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The staff has subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident.
The deletion of the requirements for the hydrogen recombiner and hydrogen monitors resulted in numbering and formatting changes to other TS, which were otherwise unaffected by this proposed amendment. The NRC staff has confirmed that the related changes are appropriate and do not affect the technical requirements.
4.0 VERIFICATIONS AND COMMITMENTS As requested by the staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.
Each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.
The licensee has verified that it has a hydrogen monitoring system capable of diagnosing beyond design-basis accidents. The licensee has committed to maintain the hydrogen monitors within its Technical Requirements Manuals. The licensee will implement this commitment within 120 days of issuance of the amendments.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.
Should the licensee choose to incorporate a regulatory commitment into the emergency plan, final safety analysis report, or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.
The staff has determined that the commitments do not warrant the creation of regulatory requirements which would require prior NRC approval of subsequent changes. The NRC staff has agreed that NEI 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff.
(See Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000.) The commitments should be controlled in accordance with the industry guidance or comparable criteria employed by a specific licensee. The staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (70 FR 5243). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: W. Reckley Date: May 26, 2005